Employer Reporting
Requirements under ACA
By: Arthur Tacchino, JD
Chief Innovation Officer
SyncStream Solutions, LLC
Reporting Requirements
• Code §6056 – Applicable Large Employer and
Offering Employer Reporting
• Code §6055 – Reporting for Employers that
Self-Insure
• W-2 Reporting
§ 6056 Reporting
•
Effective beginning in 2015 – Delayed 1 Year
–
•
Early voluntary compliance is acceptable
“Applicable Large Employers” must report,
whether they offer coverage or not
–
An employer that employed 50 or more full-time
equivalent employees in the preceding year
–
Controlled group rules apply for determining A.L.E.
Status*
A.L.E. Status
• Each Month throughout 2014:
– Identify full-time employees
– Aggregate hours of service by anyone not full-time
– Divide aggregate hours of service by 120
– Add the number of full-time employees to the
number of equivalent employees to determine the
average number of full-time equivalent employees
the employer employed that month
• January 2014
Example
– 45 full-time employees
– 15 part-timers that worked 1,200 hours
throughout the month
– 1,200 aggregate hours / 120 = 10 equivalent
employees
– 10 equivalent employees + 45 Full-time
employees = 55 Full-Time Equivalent Employees
When does employer report?
• The actual report will be much like W-2
reporting
• By January 31st of the following year
• Practically speaking the report would be
delivered in January of 2016 with 2015 plan
information
What does employer report?
• the employer’s name, date, and employer identification number (EIN);
• a certification of whether the employer offers its full-time employees and their
dependents the opportunity to enroll in “minimum essential coverage” under an
eligible employer-sponsored plan
• the number of full-time employees the employer has for each month during the
calendar year;
• the name, address, and taxpayer identification number (TIN) of each full-time
employee employed by the employer during the calendar year and the months
(if any) during which the employee and any dependents were covered under a
health benefit plan sponsored by the employer during the calendar year; and
• any other information required by the IRS
The statute also requires that employers that offer the opportunity to
enroll in “minimum essential coverage”
• must also report the months during the calendar year for which
coverage under the plan was available;
• the monthly premium for the lowest-cost option in each of the
enrollment categories under the
• plan;
• the employer’s share of the total allowed costs of benefits provided
under the plan; and
•
in the case of an employer that is an applicable large employer, the
length of any waiting period with respect to such coverage
Who gets a report?
• The employer is responsible to furnish a report for the
IRS, as well as a statement to their full-time employees
which includes:
– the name, address, and contact information of the reporting
employer; and
– the information required to be shown on the return with respect
to the individual
• *Currently the IRS is trying to “simplify” reporting
Penalties for Noncompliance
• Employer becomes subject to penalties for failure
to file an information return and failure to furnish
payee statements
• Employer shall pay a penalty of $100 for each
statement with respect to which such a failure
occurs, but the total amount imposed on such
employer for all such failures during any calendar
year shall not exceed $1,500,000
§ 6055 Reporting
•
Effective beginning in 2015 – Delayed 1 Year
–
•
Early voluntary compliance is acceptable
Code § 6055 requires insurers, sponsors of
self-insured plans, and other entities that
provide minimum essential coverage to an
individual during a calendar year to comply
with this reporting requirement
When does employer report?
• The actual report will be much like W-2
reporting
• By January 31st of the following year
• Practically speaking the report would be
delivered in January of 2016 with 2015 plan
information
What does employer report?
• the name, address, and taxpayer identification number (TIN) of the primary
insured,65 and the name and TIN of each other individual obtaining coverage
under the policy;
• the dates during which the individual was covered during the calendar year;
• if the coverage is health insurance coverage, whether the coverage is a qualified
health plan (QHP) offered through a health benefit Exchange;
• if the coverage is health insurance coverage and that coverage is a QHP, the
amount of any advance cost-sharing reduction payment or of any premium tax
credit with respect to such coverage; and
• any other information required by the IRS
In addition, under the statute, if health insurance coverage is through
an employer-provided group
• health plan, the return must contain the following information:
• the name, address, and employer identification number (EIN) of the
employer maintaining the plan;
• the portion of the premium (if any) required to be paid by the
employer; and
• any other information the IRS may require to administer the new
tax credit for eligible small employers under Code § 45R
Who gets a report?
• The employer is responsible to furnish a report for the
IRS, as well as a statement to their full-time employees
which includes:
– the name, address, and contact information of the reporting
employer; and
– the information required to be shown on the return with respect
to the individual
• *Currently the IRS is trying to “simplify” reporting
Penalties for Noncompliance
• Employer becomes subject to penalties for failure
to file an information return and failure to furnish
payee statements
• Employer shall pay a penalty of $100 for each
statement with respect to which such a failure
occurs, but the total amount imposed on such
employer for all such failures during any calendar
year shall not exceed $1,500,000
Measurement, Administrative, and
Stability Periods
• These new tracking requirements will dictate,
who is “full-time”, therefore, who should be
offered coverage
• Systems must be put in place
W-2 Reporting
• Became effective in 2012
• 250 W-2 Exemption still in place
• Employers required to report the aggregate
cost of employer sponsored coverage on the
employee’s W-2
• Still informational only reporting
Utilize Resources
• ACA Decision Support Tool
• ACA Dashboard
• Subsidy Determinator
• SyncACA
Q&A
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